ML20093D577
| ML20093D577 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/13/1984 |
| From: | Voigt H LEBOEUF, LAMB, LEIBY & MACRAE, ROCHESTER GAS & ELECTRIC CORP. |
| To: | SLADE, M.R. |
| References | |
| OL, NUDOCS 8407170072 | |
| Download: ML20093D577 (7) | |
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UNITED STATES OF AMERICA Uili':C NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING B ARd " I6 P 7 :02 In the Matter of )
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ROCHESTER GAS AND ELECTRIC CORPORATION ) Docket No. 50-244'OL_
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(R.E. Ginna Nuclear Power Plant, )
Unit No. 1) )
INTERROGATORIES PROPOUNDED TO THE INTERVENOR BY ROCHESTER GAS AND ELECTRIC CORPORATION Rochester Gas and Electric Corporation ("Appli- ;
cant") requests that Michael R. Slade, Intervenor in the above-captioned proceeding ("Intervenor"), answer under oath and in accordance with all app,licable rules of procedure the following interrogatories, basing such answers upon all information available to him.
In answering each interrogatory:
(a) Identify each document relied upon in prepar-ing the answer.
(b) To the extent that the answer is not based upon any document, identify each person to whom the informa-tion furnished in the answer is a matter of personal knowl-edge.
'7 8407170072 840713 DR ADOCK 0500024
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(c) Identify each person who assisted or partic-ipated in preparing and/or supplying any of the information given in answer to or relied upon in preparing the answer.
(d) Identify each person expected to be called by the Intervenor as a witness at the hearing, the subject matter on which he is expected to testify, and the substance of his testimony.
Definitions
" Identify" shall mean:
(i) With respect to a statute, regulation, rule, license provision, or technical specification, to set forth its citation in official form and to include its effective dates; (ii) With respect to a person, to set forth his or her name, present or last known business and home addresses, and present or last known employer and position; (iii) With respect to a document, to set forth its date, author, addressee, generic description (e.g.,
sorksheet, letter, telex, etc.), substance, present custodi-an, and Nuclear Regulatory Commission or other reference number; (iv) With respect to an oral communication or l statement, to set forth each party thereto, the date and 1
location thereof, the generic description thereof (e.g.,
telephone conversation, meeting, etc.), and the substance
thereof and to identify each document relating or referring thereto; and (v) With respect to an act or occurrence, to set forth each person who participated; each person, who if not a participant, was present; the nature of the act or occur-rence; the place and date of the act or occurrence; and each document that evidences, discusses, or relates to the act or occurrence.
In accordance with 10 C.F.R. S 2.740b (b) , the Intervenor is required to serve a copy of his answers upon all parties to the proceeding within 14 days after service of the interrogatories. Furthermore, the Intervenor is under a duty promotly to amend his answers if, after he has submitted them, he obtains information upon the basis of which (i) he knows that the answer was incorre'ct when made, or (ii) he knows that the answer though correct when made is no longer true and the circumstances are such that a failure to amend the answer is in substance a knowing concealment.
In addition, the Intervenor is under a duty promptly to supplement his answer to any question addressed to the identity of each person expected to be called as a witness at the hearing, the subject matter on which he is
_4o expected to testify, and the substance of his testimony.
See 10 C.F.R. S 2.740 (e) .
Interrogarcries
- 1. . With respect to Contention A, paragraph a), identify by manufacturer, manufacturer's designation and/or serial number, and location at the Ginna facility those electric type valve operators for which malfunctions have not been corrected.
- 2. With respect to Contention A, paragraph c), (a) describe in detail what is " inadequate" about Applicant's operations program for inspection of activities affecting
. quality and how such program fails to meet the inspection criteria set forth in 10 C.F.R. Part 50, Appendix B, criterion X; (b) describe in detail what you contend Applicant should do to correct each of the " inadequacies" identified in your response.
- 3. With respect to Contention E, describe in detail the effect of cold shock on lake biota resulting from (a) emergency shutdown of the Ginna facility, and (b)
-recirculation of discharge water into the intake water during winter when lake ambient temperature falls below 37*F.
- 4. With respect to Contention K, (a) identify your criteria for determining when radwaste systems releases are at a level "as low as reasonably achievable"; (b) describe r in detail what is " inadequate" about Applicant's radwaste systems management program and what you contend applicant should do to bring the radwaste systems releases at the Ginna facility to a level "as low as reasonably achievable."
LeBOEUF, LAMB, LEIBY & MacRAE By dA/34/ . &
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()rtner g 1333 New Hampshire Avenue, N.W. [
Suite 1100 Washington, DC 20036 Attorneys for Rochester Gas and Electric Corporation i
July 13, 1984 f
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t UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING BOARD In the Matter of )
)
ROCHESTER GAS AND ELECTRIC CORPORATION ) Docket No. 50- 244 '
)
(R.E. Ginna Nuclear Power Plant, ) ;
Unit No. 1) )
CERTIFICATE OF SERVICE I hereby certify that copies of " INTERROGATORIES PROPOUNDED TO THE INTERVENOR BY ROCHESTER GAS AND ELECTRIC CORPORATION" in the above-captioned proceeding have been served on the following by deposit in the United States mail, first class, this thirteenth day of July, 1984.
Herbert Grossman, Esq., Chairman Mr. Michael L. Slade Administrative Judge 12 Trailwood Circle Atomic Safety and Licensing Board Rochester, New York 14618 U.S. Nuclear Regulatory Commission Washington, DC 20555 Ezra Bialik Assistant Attorney General Dr. Richard F. Cole Environmental Protection Administrative Judge Bureau Atomic Safety and Licensing Board New York State Department of U.S. Nuclear Regulatory Commission Law Washington, DC 20555 2 World Trade Center New York, NY 100,47 Dr. Emmeth A. Luebke Administrative Judge Mr . Rober t N. P.nkney Atomic Safety and Licensing Board Supervisor U.S. Nuclear Regulatory Commission Town of Ontario Washington, DC 20555 107 Ridge Road West ,
Ontario, New YorA 14519 Mitzi A. Young, Esq.
Mary E. Wagner, Esq. Stanley B. Klimberg, Esq.
Counsel for NRC Staff General Counsel ;
U.S. Nuclear Regulatory Commission Jay Dunkleberger Wasnington, DC 20555 New York State Energy Office Agency Builaing 2 Empire State Building Albany, New York 12223
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Atomic Safety and Licensing Atomic Safety and Licensing l Board Panel Appeal Board Panel i U.S. Nuclear Regulatory Commission U.S. Nuclear Regulatory i Washington, DC 20555 Commission Washington, DC 20555 .
Mr. Roger W. Kober Vice President Docketing & Service Section Electric and Steam Production Office of the Secretary Rochester Gas and Electric U.S. Nuclear Regulatory Corporation Commission 89 East Avenue Washington, DC 20555 Rochester, NY 14649 -
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AMrst Harry H.g oigt (J !
Counsel Yor Applicant l l,
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